Jones v. Farmers Insurance Exchange
2012 UT 52
| Utah | 2012Background
- Chad Jones sued Farmers Insurance Exchange for breach of contract, bad faith breach of contract, and intentional infliction of emotional distress after denial of his UIM claim.
- Farmers asserted the denial was fairly debatable and sought summary judgment on that defense.
- Jones had a 2005 underinsured motorist claim for the full $30,000; a dental injury dispute arose from expert Dr. Hughes's report four years after the accident.
- Farmers questioned causation and documented internal logs suggesting insufficient support to include the $14,000 treatment in the claim.
- An arbitration awarded $18,500 to Jones, which Farmers satisfied; Jones then challenged the district court’s summary judgment ruling denying bad-faith claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the fairly-debatable defense can be resolved by summary judgment | Jones | Farmers | Not necessarily; triable questions of fact may exist |
| Whether Jones's dental claim was fairly debatable as a matter of law | Jones | Farmers | Not for this case; issue presents triable facts for jury |
| Whether the district court properly granted summary judgment on the merits | Jones | Farmers | Reversed and remanded for trial on triable issues |
Key Cases Cited
- Beck v. Farmers Ins. Exch., 701 P.2d 795 (Utah 1985) (implied good-faith duties to investigate and evaluate claims)
- Billings ex rel. Billings v. Union Bankers Ins. Co., 918 P.2d 461 (Utah 1996) (discretion in fairly-debatable determinations; jury question feasible)
- Prince v. Bear River Mut. Ins. Co., 56 P.3d 524 (Utah 2002) (legitimate factual issue can render claim fairly debatable)
- Callioux v. Progressive Ins. Co., 745 P.2d 838 (Utah Ct.App.1987) (fairly-debatable determination may depend on investigations and related proceedings)
- Salt Lake City Corp. v. Big Ditch Irrigation Co., 258 P.3d 539 (Utah 2011) (context for summary-judgment standards in Utah)
- Jackson v. Dabney, 645 P.2d 613 (Utah 1982) (reversal of summary judgment in professional-context case)
- Ault v. Holden, 44 P.3d 781 (Utah 2002) (procedural guidance on summary judgment standards)